Columbia River System Operations
Comment & Response
of bluefish.org

Cover Letter
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Conservation
Coal
Carbon Sequestration
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Irrigation
Barging Wheat
Barging Salmon and Steelhead
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Survival of Salmon and Steelhead
Juvenile Survival through Hydrosystem
     Water Temperature
     Predation by Birds
Ocean Conditions
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Greenhouse Gases
An Adequate Power Supply
An Economic Power Supply
A Reliable Power Supply
An Efficient Power Supply
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Potatoes, Apples & Grapes
Petroleum to Pasco
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Orca and Idaho's Chinook
Flex Spill to 125% TDG
Breach Lower Snake River Embankments
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Social Effects
Cultural Resources
Environmental Justice
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Conclusion

bluefish had 45 days to prepare the following comment                      
Conservation, comment by bluefish.org, response by CRSO.info
 
Conservation, comment by bluefish.org, response by CRSO.info
Federal Response:
This comment is consistent with the findings of this EIS. Conservation expectations are included in the load forecast used to establish Loss of Load Probability (LOLP) under the No Action Alternative and are included similarly in all of the other alternatives (See Appendix H, Power and Transmission, Section 2.2, H-2-3 in the Draft EIS). Therefore, the full curve of expected conservation acquisitions is considered before accounting for additional resource acquisitions necessary to meet regional reliability metrics.

The EIS analysis assumed that all energy efficiency assumed in the Northwest Power and Conservation Council's (Council) Seventh Plan is appropriate and, likely aggressive. The Council's recent State of the Columbia River System, Fiscal Year 2019 Annual Report, February 2020, p. 11, states:

"While the region currently is on track to meet Seventh Plan goals, there are some areas to watch including forecasts of declining savings from efficiency programs. And whether the region will identify new savings opportunities to replace those of residential lighting."

Utilities achievements in energy efficiency have been on an annual decline since 2016. Forecasts from utilities show that this trend is expected to continue, despite relatively stable funding levels. Given this trend, there is some uncertainty as to whether there will be enough savings from other mechanisms to reach the 1,400 average megawatt goal by the end of Fiscal Year 2021.

This information indicates that it would be difficult to increase the energy efficiency goals beyond the Council's Seventh Plan. Based on this information, it is not likely that substantial amounts of additional energy efficiency would be available as prices increase, such as in MO3.

bluefish counter response:
Taking a pessimistic view on conservation, the CRSO has taken a cautionary paragraph from The Council's 2019 Annual Report and skims past the optimistic paragraph immediately following the excerpt above:
As in recent years, residential lighting provided significant, and increasing, savings in 2018, totaling 39 average megawatts. Despite success in lighting, the Council expects lighting savings will decline beginning in 2020 because of an improvement to the federal efficiency standard. However, significant efficiency potential remains in the residential sector. Shifting the emphasis toward heating, ventilation, and air conditioning, and water heating, will help in meeting the efficiency potential.
The CRSO somehow then concludes that "it would be difficult to increase the energy efficiency goals", as if the "significant efficiency potential" will no longer be available for the Eighth Power Plan's goals (Draft due in February 2021).

Moreover, the price increase of a given Multi-Objective has nothing at all to do with the cost of efficiency savings. Marrying these two prices as being related is a bastardization of rational thinking.

Northwest Power & Conservation Council's The State of the Columbia River Basin: 2019 Annual Report 7000 megawatts of energy savings has accrued since 1980 under the leadership of the Northwest Power & Conservation Council


Survival of Salmon and Steelhead, comment by bluefish.org, response by CRSO.info
Federal Response:
This comment mischaracterizes the Northwest Power and Conservation Council's (Council) involvement in the development of this EIS. The Council is directed by the Northwest Power Act to establish and amend a regional fish and wildlife program and a power plan every five years. The power plan takes into account the fish and wildlife program and forecasts, based on the Administrators long term firm power supply contracts to meet demand, and the type and amount of resources (conservation, renewables, high fuel efficient generation, etc.) available for acquisition by the Administrator if they determine a need to acquire.

The CRSO EIS is conducted pursuant to different Federal statutes and regulations including, but not limited to the National Environmental Policy Act (NEPA) and the Endangered Species Act. This is not a usurpation of the Council's authority to review and amend either the fish and wildlife program or the power plan.

Since the Council is not a Federal, Tribal, state or local agency, it could not serve as a cooperating agency under NEPA. The Council received the Draft EIS when it was available for public review. The Council received periodic updates on the CRSO EIS NEPA process similar to the general public.

While the Council does not play a formal role in the EIS, the Council's 7th Power Plan was foundational to the resource cost and resource availability data provided by the plan. (See Section 3.7.3.1, Step 3: Determine Need for Potential Replacement Resources and Associated Costs, at page 3-821 in the Draft EIS; see also Appendix H, Power and Transmission, at Section 2.2).

Bonneville is the Federal agency charged with marketing the power from the Columbia River System. It is Bonneville's duty under NEPA to analyze the effects of its power marketing actions on affected resources. Bonneville must also ensure it is complying with other laws, including the Northwest Power Act. The EIS discusses this in more detail in Chapter 8.

bluefish counter response: The fact that the NW Council has been absent from this process is astounding. As experts on this subject, the Council staff could have provided an objective and impartial view of the CRSO results, but they have been silent.

Model runs of GENESYS under the "Remove Snake River Embankments" reveals that 680 MW of natural gas combined cycle combustion turbines would make for a Conventional Resource Replacement Portfolio. Meanwhile, the CRSO never admits to that fact, instead it is always the 1120MW that the entirety of MO3, which adds the Resource Replacement needs of Spill to 120% TDG, that is discussed in all its calculations.

Most recently (July - September 2020), Bonneville staff that have remained anonymous, tell bluefish that the Lower Snake River dams represent 90% of the MO3 Resource Replacement Portfolio. Bonneville continues stubbornly to refuse that 680 / 1120 = 60%. Instead, Bonneville staff continues to insist that 980 aMW is necessary for a Resource Replacement Portfolio.

Using the values from the CRSO EIS, the generation of the lower Snake River dams compared to the generation loss in MO3 can be computed as 980 aMW / 1,100 aMW = 89% which we describe as "about 90%."
-- email to bluefish August 6, 2020